Second Circuit Court of Appeals Reverses Work Made For Hire Decision The Second Circuit Court of Appeals had a recent occasion to discuss the issue of works made for hire. It was in the context of what constitutes a written instrument and when such an instrument needs to be signed in order to create a work made for hire. The case is The Estate of Stanley Kauffmann v. Rochester Institute of Technology and the decision was rendered on August 1, 2019. 1 It reversed the Distr